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Federal Tax Research: IRS Industry Specialization Program Coordinated Issue Papers

This guide provides information on federal tax law and identifies pertinent print and online resources available through the NYU Law Library.

IRS Industry Specialization Program Coordinated Issue Papers Basics

"The IRS formed the Industry Specialization Program (ISP)  and the Examination Specialization Program  (ESP) (formerly known as the Market Segment Specialization Program - MSSP) to promote better identification of issue for a specific industry or market during an audit.  Also, to develop a uniform and consistent treatment of  those issues.  Coordinated Issues Papers (also known as “issue papers”, or just “papers”) are designed to explain a legal issue to IRS auditors. While coordinated issue papers give guidance to examiners, coordinated issue papers are neither a service position with the status of revenue rulings or regulations, nor are they official pronouncements within the meaning of the IRC, and therefore cannot be relied upon by taxpayers. Some papers may eventually become revenue rulings, but the majority do not have ruling counterparts. . . . (Lexis)

"The Industry Specialization Program (ISP) was a national program with a national coordinator for each represented industry. This program included industries such as Aerospace, Construction/Real Estate, Health, and Petroleum and issue specialties, such as changes in methods of accounting, passive activity losses, and uniform capitalization. Previously, ISP specialists published coordinated issue papers on their industry to ensure that key industry issues were raised in all appropriate cases on a consistent basis and were resolved in a manner consistent with the guidance. These were sometimes issued in conjunction with ISP Settlement Guidelines which have been approved by IRS Appeals (also known as “Appeals Settlement Guidelines”). ISP Papers were intended primarily as an examination tool. The IRS has made its ISP Papers and ISP Settlement Guidelines publicly available on the IRS website and in redacted form where appropriate." (BNA Portfolio)

 

Sources of ISP Papers

Below are links to select sources offering field service advice.